Privacy Policy.
Coaching depends on confidentiality. This page explains what personal data Nexum collects, why it is processed, how long it is kept, and the rights you hold under the General Data Protection Regulation.
Version 1.1 · Last updated 27 July 2026
In brief: Nexum collects only the personal data reasonably needed to respond to enquiries, deliver coaching and leadership services, operate Leadership Playbook, and comply with legal obligations.
Personal data is not sold. No advertising or cross-service tracking is used. Website analytics cookies are not placed unless you actively consent.
Everything discussed in coaching remains confidential and is never reported to an employer without your agreement.
1. Who is responsible for your data
Nexum Coaching (“Nexum”, “we”, “us”) is the controller responsible for the processing described in this statement.
| Trading name | Nexum Coaching |
|---|---|
| Registered entity | ProHealthyx |
| Chamber of Commerce number | 88766756 |
| Established in | Breda, the Netherlands |
| info@nexumcoaching.com | |
| Website | www.nexumcoaching.com |
Nexum is not required to appoint a Data Protection Officer because it does not carry out large-scale monitoring or process special categories of personal data on a large scale.
Fabrizio Miccichè handles data-protection matters personally and can be contacted using the email address above. The registered postal address is available on request and through the Chamber of Commerce register.
2. Personal data we process
We process personal data because you provide it to us, because you use our services or applications, or because it is required to deliver a requested service.
Prospective clients and enquiries
This may include:
- First and last name
- Email address
- Telephone number
- Organisation name and professional role, where provided
- The content of your message and subsequent correspondence
Coaching clients and programme participants
This may include:
- Contact and organisation details
- Coaching notes, agreed goals and session records
- Assessment or questionnaire results, where used
- Dates, duration and number of coaching hours
- Video-meeting identifiers where sessions are delivered online
Organisational clients
This may include:
- Contact details of the commissioning contact
- Invoicing details, VAT numbers and purchase-order numbers
- Participant lists supplied for programme delivery
Leadership Playbook users
Leadership Playbook is a reflection and leadership-development application operated by Nexum. Depending on the features you use, the application may process the following.
Account and authentication information
- Name
- Email address
- Password stored as a protected cryptographic hash
- Internal user identifier
- Login method used
- Google or Apple authentication identifiers
- Password-recovery information
- Apple authentication information required to maintain or revoke an Apple login connection
Your Google or Apple password is never provided to Nexum.
Profile and preference information
This may include:
- Leadership focus areas
- Situations or pressure sources you identify
- Reflection preferences
- Review frequency
- Whether you work with a coach
- Other onboarding or application settings
Reflections and user-created content
This may include:
- Reflection titles and descriptions
- Answers to reflection questions
- Transcriptions
- People, projects or teams you choose to reference
- Pressure, energy or emotional-intensity ratings
- Behaviours, tags and themes
- Practices, commitments and reviews
- Saved insights
- Questions and responses created through application features
You decide what information to enter. You should avoid entering personal data about other individuals unless it is genuinely necessary for your own reflection.
Voice recordings and transcription
When you choose to record a reflection:
- The application requests access to your microphone.
- Audio is transmitted for transcription.
- Leadership Playbook temporarily processes the audio file.
- The temporary audio file is deleted after transcription.
- The resulting text is retained only if you save it as part of a reflection.
Raw audio is not intentionally stored in the Leadership Playbook database.
AI-assisted features
When you actively request an AI perspective, follow-up question or similar feature, selected reflection content is transmitted to an external AI service. This may include:
- Reflection text
- Answers to reflection questions
- Context, pressure and energy ratings
- Questions you submit
- Information needed to generate a relevant response
AI-generated summaries, observations, questions or suggested commitments may be saved with your reflection.
AI use is optional. You can use Leadership Playbook by typing reflections and saving them without requesting an AI-generated perspective.
Nexum does not use your reflections to train its own artificial-intelligence models. Processing carried out by external providers is governed by the applicable provider agreements and privacy terms.
Technical and security information
The application may process limited technical information needed for security and operation, such as:
- IP address in standard server-access logs
- Authentication attempts
- Rate-limiting information
- Time and category of an application or AI-service error
- HTTP status or operational error category
Leadership Playbook does not currently use advertising, behavioural-tracking or product-analytics SDKs.
Operational error records do not intentionally contain reflection content, prompts, authentication tokens or direct contact information.
Website visitors
If you accept analytics cookies, we may process:
- Pages viewed
- Approximate region
- Device and browser type
- Referring website
Newsletter subscribers
If you choose to subscribe, we process your name and email address. Newsletter subscription is optional and is never a condition of receiving another service.
3. Why we process personal data and the legal basis
| Purpose | Legal basis |
|---|---|
| Responding to an enquiry and arranging an introductory conversation | Consent and steps taken at your request before entering a contract — Articles 6(1)(a) and 6(1)(b) |
| Delivering coaching or a leadership programme | Performance of a contract — Article 6(1)(b) |
| Operating a Leadership Playbook account and storing the content you choose to create | Performance of a contract or provision of a requested digital service — Article 6(1)(b) |
| Providing optional voice transcription or AI-assisted reflection features | Performance of the requested service and, where appropriate, your active choice to use the feature — Articles 6(1)(b) and 6(1)(a) |
| Authenticating through Google or Apple | Performance of the requested service — Article 6(1)(b) |
| Preventing misuse, securing accounts and diagnosing technical failures | Legitimate interest in maintaining a secure and reliable service — Article 6(1)(f) |
| Maintaining a log of coaching hours required to hold and renew an ICF credential | Legitimate interest in maintaining professional accreditation — Article 6(1)(f) |
| Invoicing, bookkeeping and tax administration | Legal obligation — Article 6(1)(c) |
| Understanding how the website is used | Consent — Article 6(1)(a) |
| Sending a newsletter | Consent — Article 6(1)(a), withdrawable at any time |
The coaching-hours log records the date, duration and client identifier of each session. It is required by the International Coaching Federation for credential applications, renewal and possible audit. It contains no coaching-session content.
4. How long we keep personal data
Personal data is kept only for as long as reasonably necessary for the purpose for which it was collected.
| Data | Retention period |
|---|---|
| Enquiries that do not lead to an engagement | 24 months after the last contact |
| Coaching notes and session records | Duration of the engagement plus 2 years |
| Coaching-hours log | 7 years |
| Contracts, invoices and payment records | 7 years |
| Newsletter subscription | Until you unsubscribe |
| Website analytics data | Up to 14 months |
| Leadership Playbook account and profile data | Until the account is deleted |
| Leadership Playbook reflections, commitments, reviews and saved insights | Until deleted by the user or until the account is deleted |
| Temporary audio recordings | Deleted after the transcription request is completed |
| Password-reset information | Approximately 15 minutes, or immediately after successful use |
| Apple login nonce and state records | Approximately 5 minutes and single-use |
| Operational AI-error records | Retained for operational purposes and deleted when the associated account is deleted |
When a Leadership Playbook account is successfully deleted, the application removes the user account and associated:
- Reflections
- Commitments
- Reminders
- Reviews
- Saved insights
- AI conversation history
- Operational error records linked to the account
- Password-reset records
- Profile and authentication information
Where Sign in with Apple has been used, the application also attempts to revoke the Apple authorisation before completing deletion.
Temporary backup copies may remain for a limited technical period in infrastructure backups before being overwritten according to the relevant provider’s backup cycle. They are not restored for ordinary business purposes after a valid deletion request.
5. Confidentiality of coaching
Everything discussed during a coaching engagement is confidential.
Where an organisation commissions and pays for coaching, only information agreed in advance may be shared, such as:
- Attendance
- Progress against agreed objectives
- Non-attributable themes across a group or cohort
Individual session content is never disclosed to an employer, sponsor or colleague without the participant’s agreement.
Nexum holds an International Coaching Federation credential and works according to the ICF Code of Ethics, which establishes professional confidentiality standards in addition to applicable law.
Confidentiality may be set aside only where disclosure is legally required or where there is a serious and imminent risk of harm.
Content entered into Leadership Playbook is separate from a coaching engagement. It is not automatically shared with Nexum as coaching-session material, an employer, a coach or another organisation.
6. Sharing with third parties
Nexum does not sell personal data and does not share it for another organisation’s advertising or marketing. Information is shared only where needed to operate the service, fulfil a request or comply with a legal obligation. Where an organisation processes personal data on our instructions, we seek appropriate contractual and security safeguards.
Coaching, website and business processors
| Processor or provider | Purpose |
|---|---|
| Hostinger | Website hosting |
| Formspree | Delivery of contact-form submissions |
| Google Analytics | Website statistics, only with consent |
| Email and calendar provider | Correspondence and scheduling |
| Video-conferencing provider | Online coaching sessions |
| Accountant and bookkeeping software | Financial administration and statutory filings |
| International Coaching Federation | Coaching-hour information for credential applications, renewal or audit |
Leadership Playbook processors
| Processor or provider | Purpose and information processed |
|---|---|
| Emergent | Application hosting, database infrastructure and routing of certain AI or transcription requests |
| OpenAI | Optional voice-to-text transcription when a user records audio |
| Anthropic | Optional generation of AI-assisted reflections, observations or follow-up questions |
| Optional Google authentication | |
| Apple | Optional Apple authentication and authorisation revocation |
| Resend | Delivery of password-recovery emails |
The information sent to each provider is limited to what is needed to deliver the relevant feature.
Some providers may process personal data outside the European Economic Area. Where required, Nexum relies on recognised safeguards such as an adequacy decision, the European Commission’s Standard Contractual Clauses or another lawful transfer mechanism.
7. Cookies
The Nexum website places no analytics cookies until you actively accept them. The consent banner defaults to refused, declining is as easy as accepting, and your choice is remembered so that you are not repeatedly asked.
| Name | Type | Purpose | Expiry |
|---|---|---|---|
nexum-consent | Functional | Stores whether analytics were accepted or declined | Until site data is cleared |
_ga | Statistics, consent required | Distinguishes visitors to measure website use | 2 years |
_ga_QH96YVY7GB | Statistics, consent required | Maintains Google Analytics session state | 1 year |
No advertising, remarketing, profiling or cross-site tracking cookies are used. IP addresses are anonymised before website analytics processing. Google Consent Mode is configured so that analytics storage is denied by default.
Changing your cookie choice
You may clear the website’s data in your browser. The consent banner will then appear again and allow you to make a new choice. You can also block or delete cookies through your browser settings. The website continues to function without analytics cookies.
Leadership Playbook does not currently use advertising cookies or cross-app tracking technologies.
8. Artificial intelligence and automated decision-making
Leadership Playbook uses artificial intelligence only when a user actively requests an AI-assisted feature.
AI-generated content is intended to support reflection. It may be incomplete, inaccurate or unsuitable for a particular situation and should not be treated as professional, legal, medical or psychological advice.
Nexum does not use automated decision-making or profiling that produces legal effects or similarly significant consequences. AI-generated observations do not determine whether a user may access coaching, employment, insurance, credit or any other service.
9. Users under 16
The website, coaching services and Leadership Playbook are intended for professional adults and are not directed at anyone under 16.
We do not knowingly collect personal data from children under 16. Contact info@nexumcoaching.com if you believe that such information has been provided, and we will investigate and delete it where appropriate.
10. Your rights
Under the GDPR, you may have the right to:
- Access: know what personal data we hold and receive a copy
- Rectification: correct inaccurate or incomplete personal data
- Erasure: request deletion where there is no overriding legal requirement to retain the data
- Restriction: ask us to limit processing
- Objection: object to processing based on legitimate interests
- Portability: receive eligible personal data in a structured, machine-readable format
- Withdrawal of consent: withdraw consent at any time without affecting earlier lawful processing
Send requests to info@nexumcoaching.com. We normally respond within one month and do not charge for ordinary requests.
We may need to confirm your identity before acting. If asked to provide identification, obscure your photograph, document number, machine-readable zone and Dutch citizen service number before sending it. Never provide more information than necessary.
Leadership Playbook controls
Within Leadership Playbook, users can:
- Export their application data
- Delete individual content
- Delete their account
- Use the app without voice recording
- Deny or withdraw microphone access through device settings
- Save reflections without requesting an AI perspective
- Contact support through the application
11. Security
We use appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access and unlawful disclosure. Measures include:
- Encrypted transmission through HTTPS
- Multi-factor authentication on administrative systems
- Password and biometric protection on devices
- Restricted access to coaching records
- Passwords stored as protected cryptographic hashes
- Short-lived and single-use password-reset and Apple authentication records
- Secure token handling
- Rate limiting and authentication controls
- Data minimisation
- Processor and confidentiality agreements where applicable
- Complete application-account deletion across user-linked database records
No online system can be guaranteed completely secure. Contact info@nexumcoaching.com immediately if you believe personal data has been misused or improperly secured.
Where a personal-data breach creates a risk to individuals, Nexum will assess its reporting obligations and, where required, notify the Dutch Data Protection Authority within 72 hours. Affected individuals will also be informed where the likely risk is high.
12. Complaints
Contact us first if you are dissatisfied with how your personal data has been handled. We would prefer to investigate and resolve the issue directly.
You also have the right to lodge a complaint with the Dutch supervisory authority, the Autoriteit Persoonsgegevens.
13. Changes to this statement
When this statement changes, the version number and date at the top of the page will be updated.
Where a material change substantially affects how previously collected personal data is used, we will provide appropriate notice where contact information is available.